ERDEM-NEWSLETTER-2018-metin

90 NEWSLETTER 2018 b) Irregular and erroneous meter readings of the distributi- on companies regarding the customers of ISCs. 2. Group: Actions regarding the aggregation of the change of suppliers of non-paying customers, and increase of transacti- on costs. a) At the Stage of Participation in the Portfolio • Consumers’ participating in the ASC portfolio wit- hout a contract. • Simultaneous conclusion of retail sales contracts (subscription agreements) and bilateral agreements. • Compelling consumers to conclude bilateral agree- ments with the ASC. • ASC concluding bilateral contracts with the paying consumers, and including the said consumers into its portfolio. • ASC receiving an undated form regarding change of suppliers from consumers that it has concluded agreements with. b) At the Stage of Supply of Electricity • ASC sending a cut-off notification to non-paying consumers in violation of the legislation. • ASC shifting some of the non-paying consumers between non-paying and paying portfolios. c) At the Stage of Leaving the Portfolio • Aggregation of the change of suppliers through various provisions in the contracts and in practice. The Competition Authority evaluates the various evidence ob- tained in terms of the behaviors listed, above. In this respect, the issues related to the legal unbundling rules in the electricity sector, such as giving ASCs access to sensitive information, which is occasionally